Common use of Treatment of Reporting Singaporean Financial Institutions Clause in Contracts

Treatment of Reporting Singaporean Financial Institutions. Each Reporting Singaporean Financial Institution shall be treated as complying with, and not subject to withholding under, section 1471 of the U.S. Internal Revenue Code if Singapore complies with its obligations under Articles 2 and 3 of this Agreement with respect to such Reporting Singaporean Financial Institution, and the Reporting Singaporean Financial Institution: a) identifies U.S. Reportable Accounts and reports annually to the Singaporean Competent Authority the information required to be reported in paragraph 2 of Article 2 of this Agreement in the time and manner described in Article 3 of this Agreement; b) for each of 2015 and 2016, reports annually to the Singaporean Competent Authority the name of each Nonparticipating Financial Institution to which it has made payments and the aggregate amount of such payments; c) complies with the applicable registration requirements on the IRS FATCA registration website; d) to the extent that a Reporting Singaporean Financial Institution is (i) acting as a qualified intermediary (for purposes of section 1441 of the U.S. Internal Revenue Code) that has elected to assume primary withholding responsibility under chapter 3 of subtitle A of the U.S. Internal Revenue Code, (ii) a foreign partnership that has elected to act as a withholding foreign partnership (for purposes of both sections 1441 and 1471 of the U.S. Internal Revenue Code), or (iii) a foreign trust that has elected to act as a withholding foreign trust (for purposes of both sections 1441 and 1471 of the U.S. Internal Revenue Code), withholds 30 percent of any U.S. Source Withholdable Payment to any Nonparticipating Financial Institution; and e) in the case of a Reporting Singaporean Financial Institution that is not described in subparagraph 1(d) of this Article and that makes a payment of, or acts as an intermediary with respect to, a U.S. Source Withholdable Payment to any Nonparticipating Financial Institution, the Reporting Singaporean Financial Institution provides to any immediate payor of such U.S. Source Withholdable Payment the information required for withholding and reporting to occur with respect to such payment. Notwithstanding the foregoing, a Reporting Singaporean Financial Institution with respect to which the conditions of this paragraph 1 are not satisfied shall not be subject to withholding under section 1471 of the U.S. Internal Revenue Code unless such Reporting Singaporean Financial Institution is treated by the IRS as a Nonparticipating Financial Institution pursuant to subparagraph 3(b) of Article 5 of this Agreement.

Treatment of Reporting Singaporean Financial Institutions. Each Reporting Singaporean Financial Institution shall be treated as complying with, and not subject to withholding under, section 1471 of the U.S. Internal Revenue Code if Singapore complies with its obligations under Articles 2 and 3 of this Agreement with respect to such Reporting Singaporean Financial Institution, and the Reporting Singaporean Financial Institution: a) identifies U.S. Reportable Accounts and reports annually to the Singaporean Competent Authority the information required to be reported in paragraph 2 subparagraph 2(a) of Article 2 of this Agreement in the time and manner described in Article 3 of this Agreement; b) for each of 2015 and 2016, reports annually to the Singaporean Competent Authority the name of each Nonparticipating Financial Institution to which it has made payments and the aggregate amount of such payments; c) complies with the applicable registration requirements on the IRS FATCA registration website; dc) to the extent that a Reporting Singaporean Financial Institution is (i) acting as a qualified intermediary (for purposes of section 1441 of the U.S. Internal Revenue Code) that has elected to assume primary withholding responsibility under chapter 3 of subtitle A of the U.S. Internal Revenue Code, (ii) a foreign partnership that has elected to act as a withholding foreign partnership (for purposes of both sections 1441 and 1471 of the U.S. Internal Revenue Code), or (iii) a foreign trust that has elected to act as a withholding foreign trust (for purposes of both sections 1441 and 1471 of the U.S. Internal Revenue Code), withholds 30 percent of any U.S. Source Withholdable Payment to any Nonparticipating Financial Institution; and ed) in the case of a Reporting Singaporean Financial Institution that is not described in subparagraph 1(d1(c) of this Article and that makes a payment of, or acts as an intermediary with respect to, a U.S. Source Withholdable Payment to any Nonparticipating Financial Institution, the Reporting Singaporean Financial Institution provides to any immediate payor of such U.S. Source Withholdable Payment the information required for withholding and reporting to occur with respect to such payment. Notwithstanding the foregoing, a Reporting Singaporean Financial Institution with respect to which the conditions of this paragraph 1 are not satisfied shall not be subject to withholding under section 1471 of the U.S. Internal Revenue Code unless such Reporting Singaporean Financial Institution is treated by the IRS as a Nonparticipating Financial Institution pursuant to subparagraph 3(b2(b) of Article 5 of this Agreement.